Review of Regulation for In-Home Powerline Telecommunications (PLT) Devices

SUBMISSION TO :

Review of regulation for in-home powerline telecommunications (PLT) devices

Consultation paper

February 2016

From

DILIP K KHATRI

This submission addresses the following key topics raised in the Review paper referred to above:

Compliance status of PLT devices in Australia ( Page 7 of the Review document referred )

a)“…regulation of PLT devices have caused some confusion amongst local suppliers”

I believe that ACMA’s above comment could also be extended to cover confusion amongst users/ customers/consumers currently.

b)“Suppliers contacted by the ACMA have been unable to produce test reports demonstrating compliance against CISPR 22”

This situation in (a) above could also be a cause of the lack of test reports. It also highlights the importance of having guidelines or regulations covering this matter.

c)“…in practice the associated interference risk has not materialised. To date the ACMA has not received any complaints regarding interference to radiocommunications services from PLT devices.”

From anecdotal experience, the consumers of PLT devices in Australia are generally unaware what “authorities” they can lodge any complaints relating to interference encountered from PLT devices. Perhaps, a more widespread disclosure of avenues for lodgement of complaints re interference need to be made available to consumers. Many consumers who encounter interference from PLT devices, currently will probably discard the use of PLT and install alternatives such as CAT 5 or CAT 6 cabling, albeit at some additional cost, without lodging any formal complaints to “authorities” [ ACMA?]

Non-standard device permit from ACMA specifies:

d)“notify the ACMA of any reports the permit holder receives of interference to radiocommunications services and VDSL2 and G.fast broadband technologies, and to investigate such reports and provide a report to the ACMA; and

e)provide all reasonable assistance to users of the device, carriers and carriage service providers operating VDSL2 and G.fast systems and the ACMA in the event of any service degradation or interference reports associated with the device”

What mechanism does ACMA have to ensure compliance of the above requirements by the Suppliers within reasonable time frames? What is the nature of “all reasonable assistance” that is anticipated by ACMA? There are real concerns by consumers who have purchased PLT devices but then are unable to use it due to the interference which these causes. It seems unlikely that suppliers will refund such cost of PLT device to the affected consumers, let alone report to ACMA?

Consumer Awareness Risks

f)ACMA states “The ACMA does not believe that a localised interference risk associated with in-home PLT devices, or an interference risk that is dependent on particular conditions, should necessarily prevent the supply and operation of all such devices. However, the ACMA believes that it is appropriate that consumers be aware of any potential interference risk so that they may make an informed decision. “

It would be beneficial to consumers to be aware of the potential interference. Does ACMA suggest that such obligation for making consumers aware reside with the manufacturers, suppliers, carriers and/or carriage service providers? Without clear process, it will potentially lead to consumer confusion and lead to ill-informed decision and additional costs to the consumers.

Option 3: PLT specific standard – with mandated consumer information

g)..“The ACMA recognises that such an obligation would likely impose a financial and administrative burden on suppliers, and would therefore need to be assessed in accordance with Office of Best Practice Regulation requirements.”

Whilst such obligation would likely impose a financial and administrative burden on suppliers, it also needs to be considered in the light of additional cost burden on consumers if such obligations are not imposed on suppliers. Currently, retail telecommunications or pay TV product packages provide little option to consumers who experience interference issues with PLT devices included in the package, which necessitates additional cost of cabling for consumers.

Additional Information

“Powerline technology is subject to significant technical challenges that may make it difficult for us to meet future market requirements.”

“These technical challenges may also make it more difficult to achieve further performance improvements in powerline communications compared to other wireline communications technologies, which may put powerline communications technologies at a disadvantage as customer bandwidth requirements and interest in anywire communications technologies continue to grow. “

The paper available from the link below, also shows the numerous issues related to “Neighboring Networks Interference” associated with in-home powerline telecommunications (PLT) devices.

DILIP K KHATRI

Consumer